Selected passages from the FDA letter
Quoted FDA text from the published dataset. These selected excerpts are not the complete letter.
Passage 1Your firm did not adequately disinfect materials during transfer from the ISO 7 cleanroom into the ISO 5 hood.
Passage 2You failed to adequately disinfect containers of sterile drug components immediately prior to puncturing critical sites for use in operations.
Passage 3Your firm failed to establish adequate written responsibilities and procedures applicable to the quality control unit and to follow such written procedures (21 CFR 211.22(d)).
Passage 4Your firm failed to thoroughly investigate any unexplained discrepancy or failure of a batch or any of its components to meet any of its specifications, whether or not the batch has already been distributed (21 CFR 211.192).
Passage 5Your firm failed to establish and follow appropriate written procedures that are designed to prevent microbiological contamination of drug products purporting to be sterile, and that include validation of all aseptic and sterilization processes (21 CFR 211.113(b)).
Passage 6Your firm failed to establish adequate written procedures for production and process control designed to assure that drug products you manufacture have the identity, strength, quality, and purity they purport or are represented to possess, and to follow all of your written production and process control procedures (21 CFR 211.100(a) and (b)).
Passage 7Your firm failed to prepare batch production and control records with complete information relating to the production and control of each batch of drug product produced (21 CFR 211.188).
Passage 8Your firm failed to document at the time of performance required laboratory control mechanisms (21 CFR 211.160(a)).
Passage 9Your firm failed to have, for each batch of drug product, appropriate laboratory determination of satisfactory conformance to final specifications for the drug product, including the identity and strength of each active ingredient, prior to release (21 CFR 211.165(a)).
Passage 10Your firm failed to establish and document the accuracy, sensitivity, specificity, and reproducibility of its test methods (21 CFR 211.165(e)).
Passage 11Your firm failed to establish and follow an adequate written testing program designed to assess the stability characteristics of drug products and to use results of stability testing to determine appropriate storage conditions and expiration dates (21 CFR 211.166(a)).
Passage 12Your firm failed to establish an adequate system for monitoring environmental conditions in aseptic processing areas (21 CFR 211.42(c)(10)(iv)).
Passage 13Your firm failed to exercise appropriate controls over computer or related systems to assure that only authorized personnel institute changes in master production and control records, or other records (21 CFR 211.68(b)).
Passage 14Failure to Report Adverse Events
Passage 15Your firm did not provide a response regarding the use of **(b)(4)** to record batch production information on **(b)(4)** sheets. In addition, no response was provided regarding the **(b)(4)** test results, found in your record storage room, that were not reviewed and saved into the official batch records.
Citations in the original letter
As cited in this historical letter, not a statement of current regulatory requirements.
- 21 CFR 200.10(b)
- 21 CFR 201.115
- 21 CFR 210
- 21 CFR 210.1(b)
- 21 CFR 211.22(d)
- 21 CFR 211.192
- 21 CFR 211.113(b)
- 21 CFR 211.100(a)
- 21 CFR 211.188
- 21 CFR 211.160(a)
- 21 CFR 211.165(a)
- 21 CFR 211.165(e)
- 21 CFR 211.166(a)
- 21 CFR 211.42(c)(10)(iv)
- 21 CFR 211.68(b)